Cornerstone Data Privacy Policy
1. General
1.1 Controller. Cornerstone Management Services Limited (“Cornerstone“, “we”, “us”). We process your personal data as a controller when you use our app or otherwise get in contact and communicate with us.
1.2 Applicable Law. The processing of your personal data occurs in compliance with applicable local data privacy laws, specifically the United Kingdom General Data Protection Regulation. (“GDPR“) or the United Kingdom Data Protection Act in its current form.
1.3 Content. In this Privacy Policy, we aim to inform you about our identity, the nature, scope, and purposes of data processing, including collection and usage, providing you with information regarding your rights when using the Cornerstone Property Health App.
1.4 Contact. Our general point of contact for all questions, requests, or concerns regarding the processing of personal data is the email address: enquiries@cornerstone-ltd.co.uk (“the Email Address“).
1.5 Data Protection Contact. You can contact us regarding data protection at any time through the Email Address enquiries@cornerstone-ltd.co.uk. If you have any questions regarding the processing of your personal data, please feel free to reach.
2. Categories of Personal Data We Process
2.1 Data Sources. Cornerstone processes personal data that you directly or indirectly provide to us, for example, by using our App. Please note that the specific amount of personal data we process about you depends on how the information you provide, and information provided directly from a landlord.
2.2 Categories of Personal Data We Collect from You or Generate. The following are the categories of personal data we may collect directly or indirectly from you and/or generate independently:
Identity Information: Any information identifying you as an individual, including but not limited to: name (first name, last name, initials), date of birth, email address, gender, password, property address.
Contact Information: Any information that can be used to contact you, including but not limited to: phone number, and residential property address.
Images Capture: Any images that are provided by you for the reporting of issues relating to maintenance and fault requests, should be free from any images of individuals in the property.
Profile Information: Any information you provide in your Cornerstone profile.
Financial Information: Where information relating the contracted financials (if any) of your residential tenancy agreement.
Private Communications: Communication data relating to the messaging interface offered by the Cornerstone App, between you and the landlord.
Other Information: Names of Residents, Address of your residential property, email addresses, telephone numbers, the number of bedrooms in the property, including the number of occupants.
Device Information: Any information related to your device collected by our App, including but not limited to: device EUI, device ID, operating system, and other data stored on the device when access is granted.
3. Purpose and Legal Basis for Processing Personal Data
3.1 General Information. We collect and use personal data for specific purposes but may also use personal data for other purposes if we have the necessary legal basis to do so.
In this section, we outline the scenarios and reasons for collecting and processing your personal data, along with the legal bases for these activities and the categories of personal data affected.
3.2 Communication. We process personal data to communicate with you about your user agreement, which includes sending information on changes to our Terms and Conditions or thus Privacy Policy.
The legal basis for this processing is the performance of your contract with us, and the data categories processed include Identity Information, Contact Information and correspondence. For this purpose, we may share personal data with Processors, such as Messaging Service Providers and CRM Solution Providers, or Cloud Computing service providers.
3.3 Property Maintenance Support. We process your personal data to respond to your queries and concerns regarding issues in your property.
Please note that the Cornerstone App does not process sensitive personal data, and is offered to residents and landlords for the provision of maintenance for the managed residential property.
4. Retention of Personal Data
4.1 Retention Period
To facilitate your use of our Cornerstone App, we retain personal data for as long as you maintain an account with us.
In the event that our user agreement is terminated and you do not request immediate deletion of your personal data, we will proceed to delete your information 25 months after the termination date.
Cornerstone’s primary sub-processor of personal data is Cloudways, who have implemented adequate information security organisational and technical controls for the protection of personal data.
4.2 Deletion of Personal Data
If you request the deletion of your account, or if we delete it following the retention period, your personal data processed by Cornerstone will be deleted, with the following exceptions:
- Personal data necessary for compliance with our statutory obligations will not be deleted but reduced to the minimum required.
- Personal data required for defending against legal claims, enforcing our claims, or documenting our compliance with legal obligations will also be retained but minimised to the necessary extent.
- Personal data collected for analytical purposes or research that has been irreversibly anonymized.
5. Your Rights Regarding Personal Data
5.1 Exercise Your Rights
To exercise your rights concerning personal data (referred to as “privacy rights”) as defined in the following sections or in the annexes of the Privacy Policy, please follow the steps indicated for each case. If specific steps are not defined, or if you encounter issues, please send your request via email or contact us through our postal address.
5.2 Revocation of Consent
Please note that the primary legal basis of processing is for the performance of a contract under the United Kingdom General Data Protection Regulation.
Where you have granted consent for the processing of your personal data or app permissions for specific purposes, you can withdraw (revoke) that consent at any time.
Please note however, this does not affect the legality of data processing based on consent before the revocation.
5.3 Right to Information and Access
You have the right to obtain confirmation on whether your personal data is being processed by us and, if so, to receive more specific information about the data as well as a copy of it. This information includes processing purposes, categories of data, potential recipients, and the duration of storage, as detailed in this Privacy Policy. To receive a copy of your personal data, please email: enquiries@cornerstone-ltd.co.uk
An export will include a copy of your data along with the detailed information regarding the reason for its processing. Please note that under the United Kingdom General Data Protection Regulation, Cornerstone has 30 days to comply with any request.
5.4 Right to Rectification
You have the right to request the rectification of inaccurate personal data we process about you. If the personal data is found to be incorrect, we will rectify it without undue delay and inform you of this action. Please note that (i) you can rectify much of your personal data in the settings of our products on your own, and (ii) it may not be technically feasible for us to rectify all types of data within our products.
5.5 Right to Erasure
You have the right to have personal data we store about you deleted. If you wish to exercise this right, such as by deleting your Cornerstone account, please contact us by email.
5.6 Right to Restriction of Processing
You have the right to request a restriction on the processing of your personal data in the following situations:
- The personal data is no longer necessary for the purposes for which it was collected or otherwise processed.
- You have withdrawn consent upon which the processing is based, and there is no other legal ground for the processing.
- You have objected to the processing, and there are no overriding legitimate grounds for the processing.
- The processing is unlawful.
- The personal data must be erased to comply with a legal obligation under data protection law.
5.7 Right to Data Portability
You have the right to (i) receive a copy of your data in a structured, commonly used, and machine-readable format, and (ii) transmit that data to another controller without hindrance from us. To exercise your right to data portability, please contact us by email.
5.8 Right to Object
You have the right to object at any time to the processing of personal data for which our legitimate interests are the legal basis, including profiling. You also have the right to object to the processing of personal data for direct marketing purposes.
5.9 Right to File a Complaint
You have the right to file a complaint with the United Kingdom Information Commissioner if you believe our processing of your personal data infringes data protection law.
The contact details for the appropriate authority (United Kingdom Information Commissioner) can be found on their official website.
6. Security of Processing
We are dedicated to safeguarding your personal data and have implemented suitable technical and organisational security measures to defend against unauthorised or unlawful processing, as well as accidental loss, destruction, or damage. We also require our service providers to adhere to similar standards through contractual agreements.
These security measures are regularly updated to align with the latest technological advancements. However, please be aware that any transmission of your personal data over the internet is done at your own risk. Our protection of your personal data begins only once it arrives within our area of responsibility.
7. Questions Regarding this Privacy Policy
If you have any questions or queries regarding this Privacy Policy, please contact us by email or the postal address below;
Email: enquiries@cornerstone-ltd.co.uk
24 Picton House,
Hussar Court
Westside View
Waterlooville
Hampshire
PO7 7SQ
United Kingdom
